
The ordinary dividend rate rose from 8.75% to 10.75% and the upper rate from 33.75% to 35.75% on 6 April 2026. If your SPV distributes what it earns, that is a straight increase in cost — and it changes what a property company is actually good for.
Article · 25 June 2026
From 6 April 2026 the ordinary dividend rate rose from 8.75% to 10.75% and the upper rate rose from 33.75% to 35.75%. The additional rate is unchanged at 39.35% and the dividend allowance remains at £500. The change was announced at Budget 2025.
For a landlord who holds property personally, this changes nothing. For a landlord with a property company that pays out what it earns, it is a straight increase in the cost of getting money into their own bank account — and it arrives at exactly the moment the internet is telling landlords that incorporating is the answer to everything.
A property company is taxed twice, and both layers have to be in the sum.
Corporation tax first. From 1 April 2023 the main rate is 25% on profits over £250,000 and the small profits rate is 19% on profits at or below £50,000, with marginal relief between the two producing an effective marginal rate of 26.5%. Both limits are divided by the number of associated companies and pro-rated for short accounting periods.
That last sentence is the one that catches landlords, because the classic structure is one SPV per property or one per lender. A landlord with four associated companies has a small profits limit of £12,500 and an upper limit of £62,500 in each of them, not £50,000 and £250,000. Profits that everybody assumed were taxed at 19% are in the marginal band.
Then extraction. Whatever survives corporation tax is taxed again when it comes out as a dividend, at 10.75%, 35.75% or 39.35% depending on the shareholder's other income.
Follow £10,000 of property profit inside a company through both layers, for a shareholder who is already a higher-rate taxpayer. Ignore the £500 dividend allowance and any salary. The figures are illustrative and use 2026/27 rates.
On last year's rates the same £7,350 distributed at 33.75% cost £2,480.63 and left £4,869.37. The April 2026 change therefore costs £147 on every £10,000 of profit extracted this way, which is exactly 2% of the post-corporation-tax figure.
Now compare the alternative. The same landlord holding the property personally as a higher-rate taxpayer pays 40% on £10,000 of taxable property profit and keeps £6,000. From 6 April 2027 the property higher rate becomes 42%, so they keep £5,800. Either way, personal ownership beats extraction from a company by a wide margin at this profit level.
Leave the money in the company and the picture inverts.
That is the honest conclusion, and it is not the one usually sold. A property company is no longer a cheaper way to take the same money out. It is a cheaper way to keep money in. Every additional pound retained inside a company at 19% or 26.5% instead of taxed at 40% or 45% compounds into the next purchase. Every pound extracted now costs more than it did last year.
At the small profits rate of 19% and the ordinary dividend rate of 10.75%, £10,000 of company profit leaves £8,100 after corporation tax and £870.75 of dividend tax, so the shareholder keeps £7,229.25 — a combined 27.7%. A basic-rate landlord holding the same property personally pays 20% and keeps £8,000, rising to 22% and £7,800 from April 2027. The double layer costs a basic-rate shareholder money too, just less of it.
Three things are worth separating.
Section 24 still does not apply to companies. HMRC's Property Income Manual is explicit that companies carrying on a property business are not affected by the finance cost restriction, so mortgage interest remains fully deductible against company profits. For a heavily geared portfolio that is the single largest number in the comparison and the dividend rise does not touch it.
The April 2027 property income rates do not mention companies. Individuals, partnerships, trusts and estates move to 22%, 42% and 47%; companies stay on corporation tax. That widens the retention gap further from April 2027.
Getting into a company has not become cheaper. A transfer of property to a company you control is a disposal to a connected person at market value under sections 17 and 18 TCGA 1992, taxed at 18% or 24% unless incorporation relief under section 162 applies — and from 6 April 2026 that relief has to be claimed in the Self Assessment return for the year of transfer rather than applying automatically. Stamp duty is charged on market value under section 53 Finance Act 2003, with the 5-point additional dwellings surcharge and a 17% flat rate on any single dwelling over £500,000 unless a relief such as property rental business relief applies.
The full company position — statutory accounts, corporation tax with the associated companies trap, directors' loans and the cost of taking money out — is on property company accounts, and accountants for property companies and SPVs covers how we work with landlords who already hold through a company. If you are still weighing the structure, read the incorporation guide before the incorporation calculator, because the guide contains the costs the calculator cannot know. This is information rather than advice on your own structure.
What has changed in landlord tax, the dates coming up, and one number worth checking on your own portfolio.
The ordinary rate is 10.75%, up from 8.75%, and the upper rate is 35.75%, up from 33.75%. The additional rate is unchanged at 39.35%, and the dividend allowance remains at £500. The increases took effect on 6 April 2026 and were announced at Budget 2025. Which rate applies to a particular dividend depends on where it falls once it is stacked on top of your other income, so a shareholder with a salary or substantial rental income personally may find more of a dividend taxed at the upper rate than they expect. Nothing about the change affects landlords who hold property personally rather than through a company.
Two per cent of every distribution below the additional rate threshold. Illustratively, £10,000 of company profit taxed at the marginal corporation tax rate of 26.5% leaves £7,350. Distributed at the new upper rate of 35.75% that costs £2,627.63, against £2,480.63 at last year's 33.75%, so the shareholder is £147 worse off on each £10,000 of profit extracted. On £60,000 of profit extracted in a year that is £882. The additional rate is unchanged at 39.35%, so a shareholder whose dividends fall entirely in the additional rate band is not affected by this particular change at all.
It depends entirely on whether you draw the profit or keep it. On extraction the company is clearly worse: illustratively £10,000 of profit in the marginal corporation tax band leaves a higher-rate shareholder £4,722.37, against £6,000 for the same profit held personally. On retention the company is clearly better: £7,350 stays in the business at 26.5%, or £8,100 at 19%, while an individual landlord pays 40% on the profit whether or not they spend it. Add that companies are outside Section 24 so mortgage interest is fully deductible, and the picture is that a company suits a portfolio being built, not a portfolio being lived on.
The corporation tax limits are divided by the number of associated companies. The small profits rate of 19% applies to profits at or below £50,000 and the main rate of 25% above £250,000, but a landlord with four associated companies has a small profits limit of £12,500 and an upper limit of £62,500 in each company. The limits are also pro-rated for accounting periods shorter than twelve months. Because the classic landlord structure is one SPV per property or one per lender, this catches a lot of people who set the companies up on the assumption that each would enjoy the full £50,000 band, and it moves profits into the 26.5% marginal band that were budgeted at 19%.
The dividend rise is a reason to look harder at the whole comparison, not a reason to move in either direction. Incorporating removes Section 24, because companies are outside the finance cost restriction, and it lets profits be retained at 19% to 26.5% rather than taxed at 40% or 45%. In exchange it creates a capital gains disposal at market value to a connected person, stamp duty on market value with the 5-point surcharge and possibly the 17% corporate flat rate, and a second layer of tax on everything extracted. Since 6 April 2026 incorporation relief also has to be claimed on your tax return rather than applying automatically. It is a calculation, not a rule.
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